Page 1 - iba White_Paper_for_BICC

IBA Draft of presentation to IC Commissioners in January after meeting between Jane Seymour, counsel
for IBA, and IC Prosecutors
For Settlement Purposes Only. Not for distribution to Defendants or their attorney, or to IC
Commissioners, until released by Jane Seymour

Greeting

Good Morning, Commissioners. Thank you for agreeing to meet with me today.

Introduction

My name is Jane Seymour, Counsel for Island Beach Access (IBA), a party
intervener in the lawsuit Island County (IC) v Montgomery. I have represented
IBA pro bono since December of 2014. This lawsuit concerns the ownership of
Wonn Road and tidelands, a dedicated county road leading to navigable waters of

Puget Sound.

Importance of Public Beach Access

Public beach access is one of Island County’s most precious economic resources
for tourists and residents alike. Simply put, public beaches bring visitors to Island
County who spend money. Due to the extreme limit on the amount of public

beach access and the numerous cases of unlawful private encroachment onto
public beach access, IBA’s mission is timely and critical.

IBA Introduction and Role in the Lawsuit
IBA is a Washington nonprofit community service organization whose mission is to
identify, map, sign, and preserve access to the public shorelines of Island County
for everyone. The Court allowed IBA to intervene in the lawsuit because IBA

represents members of the public, each of whom have suffered unique injury and
loss as a result of the Montgomerys’ interference with the public’s legally protected
right to reach navigable water at Wonn Road.

IBA is not interested in turning private property to public use, but strongly defends
the public’s right of access to public property which is being threatened by the
defendants. Our interests align with IC in this respect.

IBA LEGAL WHITE PAPER Page 1 of 16